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Site Number: |
014L |
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Contract Number: |
EP-W-08-061 |
D.O. Number: |
0016 |
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Action Memo Date: |
1/20/2010 |
Response Authority: |
CERCLA |
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Response Type: |
Time-Critical |
Response Lead: |
EPA |
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Incident Category: |
Removal Action |
NPL Status: |
Non NPL |
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Operable Unit: |
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Mobilization Date: |
2/10/2010 |
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Start Date: |
2/10/2010 |
Demob Date: |
4/16/2010 |
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Completion Date: |
5/18/2010 |
CERCLIS ID: |
CTD001183052 |
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RCRIS ID: |
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ERNS No.: |
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State Notification: |
2/10/2010 |
FPN#: |
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Reimbursable Account #: |
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1.1.1 Incident Category
Time Critical Removal Action.
1.1.2 Site Description
The Site is an abandoned, privately operated metal finishing business that went out of business in 1996, and has been abandoned since. The building has deteriorated in the intervening years; there is a hole in the roof which has allowed the basement to be filled with precipitation. Evidence of use as living quarters by local indigents was observed despite repeated efforts by local authorities to secure it by boarding up windows, installing locks, and adding police patrols. Residual plating shop contaminants and sludge in vats, tanks, and throughout the building present a hazard to the indigent residents.
The building is a one-story structure of approximately 18,000 square feet with a 1000 square foot basement on approximately 0.5 acres. In addition to metal plating process residues, It contains general debris, solid waste, and biological waste composed of food scraps and human waste from indigents’ use of the facility as living quarters. The basement is flooded with about six feet of water, obstructing assessment of hazardous materials that may be in it.
1.1.2.1 Location
The Site is located in a mixed residential and commercial area adjacent to residential properties and a new greenway/recreational path on a former rail right-of-way. The address is 400 Goodrich St, Hamden, CT 06517 or 75 Daisy St, New Haven, CT 06511; the geographic position is 41 20.08’ N, 072 56.04’ W.
1.1.2.2 Description of Threat
Residual metal plating chemicals, sludge and residues present a contact hazard to local indigents using the Site as living quarters. Concentrations of metal contaminants on Site are above the CTDEP direct contact criteria for residential and commercial exposure scenarios. Due to the use of the site building, residential exposure scenario is appropriate. Mercury and PCB containing switches and fixtures are throughout the site building. Due to their degraded condition release of their contents to the building and environment is likely; thus exposing the building squatter residents and community.
The Site building has become a haven for local indigents' use as a living quarters and drug usage despite repeated attempts to secure it by town authorities. The activities result in a threat to public health and sanitation directly to those engaging in these activities and to the neighborhood and community as a whole. Indigents' attempts to heat and cook with fires and heaters and the large amount of solid debris and waste on site pose a threat of fire which could mobilize the contaminants on site and release them to the environment.
1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results
The Site contains approximately 85 metal plating vats with residual contaminants, several tanks, process piping, and fixtures containing hazardous contaminants that are in poor condition. Not including the basement, which couldn’t be inventoried; the following additional hazardous wastes and materials were identified; PCB and mercury containing light fixtures and switches and biological waste.
A total of 44 solid samples were collected inside the building from metal plating vats, tanks, the floor, walls and other components. The samples were analyzed for Resource Conservation and Recovery Act (RCRA) 8 metals, poly chlorinated biphenyls (PCB’s), asbestos, hexavalent chromium, cyanide and Toxicity Characteristic Leaching Procedure (TCLP) metals analysis. The contaminants present a risk to indigent and homeless resident trespassers because they exceed CTDEP Residential and/or Commercial/Industrial Standards; analytical results for the highest result are shown below. CTDEP Residential Remediation Standard Regulation (RSR) and CTDEP Commercial/Industrial Direct Exposure Criteria (DEC) are provided for comparison:
Contaminant
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Result, parts per million (ppm)
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CTDEP RSR, Residential,
ppm
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CTDEP DEC, Commercial/Industrial, ppm
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Antimony
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170
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27
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8200
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Cadmium
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660
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34
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1000
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Chromium (Total)
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12,000
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3900
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51,000
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Copper
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180,000
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2500
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76,000
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Lead
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980
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500
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1000
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Nickel
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540,000
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1400
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7500
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Zinc
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190,000
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20,000
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610,000
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Cyanide
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40,000
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1400
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41,000
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2.1.1 Narrative
Personnel conducted a site walk with 2 EPA OSC and the ERRS RM on 2/4/2010 to verify site conditions and then commenced lining up resources. On 2/10/2010 2 EPA OSC, 4 ERRS and 1 START personnel mobilized to the site and commenced set-up operations; clean up operations started on 2/11/2010 and the site was demobilized on 4/16/2010.
2.1.2 Response Actions to Date
2/04/2010 - 4/16/2010 - See POLREPS 1, 2, 3 and 4.
4/17/2010 - 5/18/2010
-No on-site operations this period; demobilized from the site on 4/16/2010.
-Administrative Record notices appeared in the New Haven Register on 4/9 and in the Quini[iac University Chronicle on 4/14.
-Received final weight slips for off site disposal and final 1900-55's for ERRS and final TDD Amendments from START.
-Recieved Close-Out Letter from CTDEP.
6/25/2010: The final 1900-55 report from ERRS was received and approved.
4/15/2011: The draft Removal Action Completion Report was received from START and approved to be finalized with several comments.
2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The PRP's estate has been identified and provided access consent.
2.1.4 Progress Metrics. Amounts below are approximate, preliminary figures as of POLREP date:
Waste Stream |
Medium |
Quantity |
Manifest # |
Treatment |
Disposal |
Non-Haz, 30 cuyd containers; 9 total |
Solid |
103,840 Lbs. |
N/A |
None |
Pine Ave Landfill
Niagra Falls, NY |
Scrap Metal, 20 cuyd containers; 9 total |
Solid |
69,620 Lbs. |
N/A |
None |
Sims Metal Management, North Haven, CT |
Basement and Vat Water |
Liquid |
100,000 + 2000 Gallons |
N/A |
None |
Sanitary Sewer, Greater New Haven Water Pollution Control Authority |
Vat Scrapings/Floor Sweepings, 8 Drums |
Solid |
8 Drums; billed by drum, 2400 Lbs. estimated |
006756710 JJK |
None |
Vexor Technology, Inc., Medina, OH 44256 |
PCB Ballast, Mercury Tube Lamps, HID Lamps, Misc Wastes; 3 Drums, 1 Pail, 8 Boxes |
Solid |
873 Lbs. |
006756711 JJK, none |
None |
Complete Recycling Solutions, Fall River, MA 02720 |
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